Object

Representation ID: 43861

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

6.3 Policy HW2 deals with healthcare infrastructure. Amongst other things it identifies that all residential developments of 10 or more units must be assessed against the capacity of existing healthcare facilities. Where demand generated by residents of the new development would have unacceptable impacts upon the capacity of these facilities, developers would be required to contribute to the provision and improvement of such services.
6.4 It is the position of Taylor Wimpey that contributions towards both the provision of acute NHS services and services provided by the CCG are not, as yet, universally verified as being compliant with the tests set out in the NPPF for lawful planning obligations. As such the element of Policy HW2 relating to such contributions should be removed.
6.5 In addition, Criterion 5 refers to infrastructure contributions being sought on-site or its immediate vicinity. It would be wholly impractical for development of 11 dwellings to deliver infrastructure for healthcare on-site. In addition, it has been proved in a number of locations that where land is set aside to provide for new medical facilities, the delivery of these facilities has proved problematic, and the land becomes surplus. The delivery of specific medical facilities falls outside of the remit for most developers, particularly those engaged in house building. The policy should pay regard to these factors.
6.6 Whilst supporting paragraph 5.30 highlights that whilst many healthcare infrastructure projects will be delivered from mainstream NHS resources, contributions would also be secured through planning agreements in line with the relevant regulations in operation at the time. As stated above, there is some uncertainty as to whether contributions towards such facilities (NHS CCG services) are in accordance with the current CIL Regulations.
6.7 The policy and its supporting text refer to the 'sequential test'. It is unclear why the sequential test is being referred to in the context of the delivery of contributions towards healthcare whether it be on-site or off-site. In planning terms, a sequential test either relates to the location of development relative to areas of flood risk or town centres.
6.8 Paragraph 5.32 refers to the Viability and Delivery Study indicating that, depending on the extent of other planning obligations, contributions towards healthcare provision as required in the policy may not be viable. This contradicts the approach set out in the previous policy DEL1 which states that the Plan has been subject to a viability assessment to ensure policies are deliverable and the supporting text confirms (paragraph 4.21) that greenfield sites will be able to sustain the full range of planning obligations required. As set out above, depending on its site specific S106 requirements, it may well be the case that sites in Plan cannot deliver the full range of planning obligations.